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doubt that the plaintiff can prove no set of facts in support of his claim that would entitle him to relief." Id, (abrogating and quoting Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme Court rejected the notion that "a wholly conclusory statement of claim [can
ntitle[ment] to relief' requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do, see Papasan v. Allain, 478 U.S. 265, 286, 106 S.Ct. 2932, 92 L.Ed.2d 209 (1986) (on a motion to dismiss, courts "are not bound to accept as true a legal conclu
oubt that the plaintiff can prove not set of facts in support of his claim that would entitle him to relief." Id, (abrogating and quoting Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme Court rejected the notion that "a wholly conclusory statement of claim [can
ntitle[ment] to relief' requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do, see Papasan v. Allain, 478 U.S. 265, 286, 106 S.Ct. 2932, 92 L.Ed.2d 209 (1986} (on a motion to dismiss, courts "are not bound to accept as true a legal conclu
o relief." Id, (abrogating and quoting Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d
e elements of a cause of action will not do, see Papasan v. Allain, 478 U.S. 265, 286, 106 S.Ct. 2932, 92
d later). “[Llegal conclusions done up as factual allegations are not facts and cannot substitute for facts.” Cornell, 2000 WL 284222, at *2 (citing Papasan v. Al- lain, 478 U.S. 265, 286, 106 S.Ct. 2932, 92 L.Ed.2d 209 (1986)). Plaintiffs have note provided an “outline of how their showing of minimum con
Page: HOUSE_OVERSIGHT_017878 →t, “even when the complaint is liberally con- strued, that the plaintiff can prove no set of facts which would entitle him to relief.” Id.; Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957). Federal Rule of Civil Procedure 8(a) requires that a complaint contain “a short and plain stat
Page: HOUSE_OVERSIGHT_017890 →Entities connected to both Gibson and Papasan

Jeffrey Epstein
PERSON
United States
LOCATION
Supreme Court
ORGANIZATION
Scarlett Johansson
PERSON
Virginia Giuffre
PERSON
Wilbur Ross
PERSONJane Doe
PERSONConley
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSONSullivan
PERSON
Kenneth Marra
PERSONTwombly
PERSONWright
PERSON
Rhodes
PERSONMichael J. Pike
PERSON
Adam D. Horowitz
PERSONStuart S. Mermelstein
PERSON
Jeffrey Marc Herman
PERSONRobert D. Critton
PERSON